PUBLIC INTEREST ADVOCACY CENTRE

LE CENTRE POUR LA DÉFENSE DE L’INTÉRÊT PUBLIC

285 McLeod Street, Suite 200, Ottawa, ON K2P 1A1

5 August 2020

Mr. Claude Doucet

Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, ON K1A 0N2
VIA GC KEY

Re: Telecom Notice of Consultation CRTC 2019-57, Notice of

Hearing, Review of mobile wireless services,
Answer of the Coalition for Cheaper Wireless Service (CCWS) to
Bell Mobility Procedural Request of 4 August 2020

Dear Mr. Doucet:

The Coalition for Cheaper Wireless Service (CCWS): (Public Interest Advocacy Centre
(PIAC); ACORN Canada (ACORN); National Pensioners Federation (NPF); and Canadian
Association of Retired Persons (CARP)); hereby files its answer to Bell Mobility’s (“Bell”)
procedural request of 4 August 2020.

In that procedural request, Bell requests: “a decision from the Commission to remedy
significant prejudice to our procedural fairness rights and ensure that any evidence that
could influence the Commission's decision in this proceeding has been subject to sufficient
scrutiny to have confidence in its accuracy. In particular, we are asking the Commission to
strike the Matrix Report (filed with the Further Comments of the Bureau on 22 November
2019) from the record.” The CCWS opposes both of these requests.

For clarity, the CCWS also notes that we oppose in addition the suggestion in the 31 July
2020 letter of the Competition Bureau that accompanies the revised final submissions of
the Bureau that are the subject of Bell’s discomfort, that: “Should Bell Canada wish to raise
these criticisms with the Commission, the Commissioner respectfully requests that the
Bureau and all other parties to this proceeding be afforded the opportunity to (i) comment
on each other’s Final Submissions,2 and (ii) reply to such critiques (as appropriate).”
With respect, the record is closed, or should be closed, and no further evidence, argument
or “corrections” are needed or justified. Any additional process along the lines suggested
by Bell or the Bureau, and in particular, the striking of evidence (the Bureau’s “Matrix
Report”) relied upon by all other participants in this proceeding would be highly prejudicial
and not remedied by yet another round of comment.

Although the CCWS represents a wide coalition of consumers, the resources of its legal
representatives has been stretched by this proceeding as it is. We would not be able to
provide an adequate argument on the argument that additional process were necessary
due to resource constraints, nor adjust and rewrite our argument, on the points that Bell
continues to seek to argue after the record is closed.

The CCWS frankly is shocked and dismayed at the exchange of letters between two
participants in the proceeding to “adjust” evidence without transparency to other parties.
To see this exchange then used as a justification to demand out of process and frankly,
unprecedented calls for additional argument about FINAL REPLIES that all parties have
otherwise treated as final is more than inappropriate. It is in fact an abuse of process.

The Commission should swiftly reject Bell’s request to strike relied-upon evidence from the
record, and should have already rejected the “adjusted” evidence or argument of the
Bureau without notice to parties (beyond this information simply being posted on the
Commission’s proceeding-specific portion of its website). The Commission is perfectly
capable of evaluating the Bureau’s reports, evidence and argument without Bell’s
incessant hectoring and out-of-process rearguing of its case in the guise of a lengthy
procedural request.

We oppose any further process. The consumer interest is in a swift resolution of the
matters at issue in this very important process.

Sincerely,

John Lawford
Counsel to the CCWS

cc: Parties to TNC 2019-57

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